Finding 558086 (2024-001)

-
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-04-29

AI Summary

  • Core Issue: Deficiencies in tenant files indicate non-compliance with HUD requirements.
  • Impacted Requirements: Missing forms and verifications violate the Authority’s Administrative Plan and 24 CFR 982.516.
  • Recommended Follow-Up: Train staff on procedures, correct noted deficiencies, and assess the impact on all tenant files.

Finding Text

Condition: Out of an approximate population of 20,000 of Housing Voucher Cluster, 40 tenant files were tested and the following deficiencies were noted: • One file did not have the required 214 declaration form; • Two files could not support the utility allowance calculation; • One file did not have third party verification of income; and • One file did not have the required rent reasonableness check. Criteria: The Authority’s Administrative Plan and 24 CFR 982.516 requires internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Context: The auditor randomly selected tenant files out of the population from each program as outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing turnover and did not have the available staff to fully implement the established internal controls to ensure proper compliance with regards to timely recertifications and collection of required HUD documentation to complete the tenant files. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown Auditor Recommendations: The Authority should continue to train staff on the established procedures and controls in place to ensure full compliance in regard to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See the Corrective Action Plan in this report

Corrective Action Plan

Ensure full compliance with HUD regulations and internal policies related to eligibility documentation, income verification, utility allowances, and rent reasonableness determinations in the Housing Choice Voucher (HCV) program. 1. Correct the Deficiencies in the Identified Files Issue Missing 214 Declaration Form Utility Allowance Calculation (2 files) Missing Third-Party Income Verification Missing Rent Reasonableness Determination Action Contact tenant to obtain and file the signed 214 declaration. Recalculate and document the utility allowance using the current approved utility schedule. Request and obtain third-party verification; if unavailable, follow up with tenant and document efforts per HUD guidelines. Conduct and document rent reasonableness review for the current unit. Responsible Party Housing Specialist Housing Specialist Housing Specialist HQS/Rent Reasonableness Officer Timeline Within 10 business days Within 10 business days Within 10 business days Within 10 business days 2. Expand Review to Broader File Population Action Details Responsible Party Timeline Risk-based Review of Additional Files Identify Systemic Issues Report Findings Identify a representative sample of 100-200 files from the broader tenant population to assess the prevalence of the noted deficiencies. Track and categorize findings to identify patterns of noncompliance. Present findings to leadership and recommend procedural changes if systemic issues are found. Quality Assurance (QA) Team QA Manager QA Manager Within 45 days Within 60 days Within 75 days 3. Strengthen Policies, Procedures, and Staff Training Update Procedures Revise Standard Operating Procedures (SOPs) for file documentation, utility allowances, and rent reasonableness. Include clear checklists. Program Manager Within 90 days Staff Training Conduct mandatory refresher training on eligibility documentation,income verification protocols, rent reasonableness, and utility allowance schedules. File Audit Checklist Implement a standardized checklist for file reviews before final approval. 4. Ongoing Monitoring and Compliance Quarterly File Audits Continue random quarterly audits of tenant files to ensure ongoing compliance. Compliance Reporting Include compliance metrics in monthly management reports. Corrective Action Tracking Maintain a tracking system for noted deficiencies and corrective actions taken.

Categories

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.850 Public Housing Operating Fund $10.35M
14.872 Public Housing Capital Fund $8.58M
14.879 Mainstream Vouchers $1.67M
14.871 Section 8 Housing Choice Vouchers $1.22M
14.238 Shelter Plus Care $592,432
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $507,085
14.870 Resident Opportunity and Supportive Services - Service Coordinators $435,735
14.889 Choice Neighborhoods Implementation Grants $109,727
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $24,953